ML12081A016

Supplemental Response to Request for Additional Information Related to License Amendment Request for Permanent Alternate Repair Criteria for Steam Generator Tube Inspection and Repair

ML12081A016
Person / Time
Site:	Surry
Issue date:	03/14/2012
From:	Lane N Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-028a
Download: ML12081A016 (7)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 14, 2012 10CFR50.90 U.S. Nuclear Regulatory Commission Serial No. 12-028A Attention: Document Control Desk SPS/LIC-CGL RO' Washington, D.C. 20555 Docket Nos. 50-280/281 License Nos. DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS I AND 2 SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR PERMANENT ALTERNATE REPAIR CRITERIA FOR STEAM GENERATOR TUBE INSPECTION AND REPAIR By letter dated July 28, 2011 (Serial No.11-403), Dominion requested a license amendment request in the form of a change to the Technical Specifications (TS) to Facility Operating License Numbers DPR-32 and DPR-37, for Surry Power Station Units 1 and 2, respectively.

This amendment request proposes to permanently revise TS 6.4.Q, "Steam Generator (SG)

Program," to exclude portions of the SG tube below the top of the SG tubesheet from periodic inspections and to revise TS 6.6.A.3, "Steam Generator Tube Inspection Report,"

to provide reporting requirements specific to the permanent alternate repair criteria.

An NRC letter, dated January 18, 2012 [ADAMS Accession No. ML12006A001], provided a request for additional information (RAI) regarding the permanent alternate repair criteria amendment request for Surry. The response to the RAI was provided by our letter dated February 14, 2012 (Serial No.12-028). In response to RAI Question 15, the current TS primary to secondary leakage limit of 150 gallons per day (gpd) was revised to 83 gpd.

During a March 6, 2012 conference call with the NRC staff, the NRC indicated that, upon further review, the revision to the TS primary to secondary leakage limit was not necessary.

The NRC confirmed their conclusion in a subsequent NRC e-mail dated March 7, 2012 to Dominion from the Surry NRC Project Manager.

Based on this communication, Dominion is supplementing the response to RAI Question 15 to retain the current TS primary to secondary leakage limit of 150 gpd in TS 3.1.C and TS 4.13. However, the portion of the RAI Question 15 response that addressed a minor administrative revision to reinstate the superscripted number 1 at the end of the TS 4.13.B text is not impacted by this letter. Thus, the marked-up and typed pages included in Attachments 5 and 6, respectively, in our February 14, 2012 letter are replaced in their entirety by the marked-up and typed page included in Attachments 1 and 2, respectively, to this letter.

AO 0

Serial No. 12-028A Docket Nos. 50-280/281 Permanent Alternate Repair Criteria Supplemental RAI Response Page 2 of 3 The supplemental RAI response provided by this letter does not affect the significant hazards consideration determination or the environmental consideration that was previously provided in support of the permanent alternate repair criteria amendment request.

As stated in our July 28, 2011 and February 14, 2012 letters, approval of the proposed permanent alternate repair criteria is requested for Surry Units 1 and 2 by April 2, 2012 with a 30-day implementation period. The requested approval schedule is necessary to support the Surry Unit 1 Refueling Outage 24 (Spring 2012), since the Unit 1 existing one-time alternate repair criteria approved by Unit 1 Amendment 267 expires at the end of the current operating cycle. This amendment will be implemented prior to the 200 degree F mode change during startup following the Unit 1 Refueling Outage 24.

If you have any questions or require additional information, please contact Mr. Gary Miller at (804) 273-2771.

Sincerely, N. L. Lane Site Vice President Surry Power Station COMMONWEALTH OF VIRGINIA )

COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by N. L. Lane who is Site Vice President - Surry Power Station, Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this day of ,2012.

My Commission Expires: )-*0/W '\ &O.

Notary Public*

LORI TYLER HUSKEY Notary Public Commonwealth of Virginia My Commission Expires October 31, 2015 Commission 1D# 150293

Serial No. 12-028A Docket Nos. 50-280/281 Permanent Alternate Repair Criteria Supplemental RAI Response Page 3 of 3 Attachments:

1. Marked-up Technical Specifications Page

2. Proposed Technical Specifications Page Commitments made in this letter: None.

cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219 NRC Senior Resident Inspector Surry Power Station Ms. K. R. Cotton, NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas, NRC Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852

Serial No. 12-028A Docket Nos. 50-280/281 ATTACHMENT 1 MARKED-UP TECHNICAL SPECIFICATIONS PAGE RELATED TO LICENSE AMENDMENT REQUEST FOR PERMANENT ALTERNATE REPAIR CRITERIA FOR STEAM GENERATOR TUBE INSPECTION AND REPAIR VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS I AND 2

TS 4.13-1 2-444 4.13 RCS OPERATIONAL LEAKAGE Applicability The following specifications are applicable to RCS operational LEAKAGE whenever Tavg (average RCS temperature) exceeds 200'F (200 degrees Fahrenheit).

Objective To verify that RCS operational LEAKAGE is maintained within the allowable limits, the following surveillances shall be performed at the frequencies specified in the Surveillance Frequency Control Program.

Specifications A. Verify RCS operational LEAKAGE is within the limits specified in TS 3.1.C by performance of RCS water inventory balance. 1,2 B. Verify primary to secondary LEAKAGE is < 150 gallons per day through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the to secondary LEAKAGE should be conservatively assumed to be from one Notes:

1. Not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

BASES SURVEILLANCE REQUIREMENTS (SR)

SR 4.13.A Verifying RCS LEAKAGE to be within the Limiting Condition for Operation (LCO) limits ensures the integrity of the reactor coolant pressure boundary (RCPB) is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be performed with the reactor at steady state operating conditions (stable pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The surveillance is modified by two notes.

Note 1 states that this SR is not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable unit conditions are established.

Amendment Nos.-3 n 49

Serial No. 12-028A Docket Nos. 50-280/281 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE RELATED TO LICENSE AMENDMENT REQUEST FOR PERMANENT ALTERNATE REPAIR CRITERIA FOR STEAM GENERATOR TUBE INSPECTION AND REPAIR VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS I AND 2

TS 4.13-1 4.13 RCS OPERATIONAL LEAKAGE Applicability The following specifications are applicable to RCS operational LEAKAGE whenever Tavg (average RCS temperature) exceeds 200'F (200 degrees Fahrenheit).

Objective To verify that RCS operational LEAKAGE is maintained within the allowable limits, the following surveillances shall be performed at the frequencies specified in the Surveillance Frequency Control Program.

Specifications A. Verify RCS operational LEAKAGE is within the limits specified in TS 3.1.C by 1

performance of RCS water inventory balance. ' 2 B. Verify primary to secondary LEAKAGE is _<150 gallons per day through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.'

Notes:

1. Not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

BASES SURVEILLANCE REQUIREMENTS (SR)

SR 4.13.A Verifying RCS LEAKAGE to be within the Limiting Condition for Operation (LCO) limits ensures the integrity of the reactor coolant pressure boundary (RCPB) is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be performed with the reactor at steady state operating conditions (stable pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The surveillance is modified by two notes.

Note 1 states that this SR is not required to be completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable unit conditions are established.

Amendment Nos.